Introduction
The airworthiness (initial and continuing) of the aircraft referred to in Annex II to the Basic Regulation has to comply with the national rules of the state of registry, which may include ‘national requirements.
If the AMP is self-declared, based on the M.A.302(h) alleviation for ELA1 aircraft not involved in a commercial operation, it cannot be initially challenged by the competent authority and the owner assumes full responsibility for its content
Responsibility for Maintenance Program Approval
The Agency is, on behalf of the Member States, the competent authority for initial airworthiness as per article 20(1) of Regulation (EC) 216/2008 (the EASA ‘Basic Regulation’). Following M.A.302(d)(ii), those ICA shall be the basis to develop an AMP. (based on compliance with the instructions for continuing airworthiness (ICA) issued by the design approval holder during the certification process with the Agency)
Whilst the Operator Owns the Aircraft Maintenance Program, EASA Member State’s competent authorities are responsible for approving the AMP
Note 1 – The intention of the rule is that they should not impose aeronautical instructions (such as national requirements) However, competent authorities may issue alternate instructions to ICA when such instructions aim to offer flexibility to the operator [AMC M.A.302(d) point (2)].
Note 2 – In the case where there has been no ICA issued by the design approval holder for a particular aircraft, modification, repair or STC (Supplemental Type Certificate) then competent authorities may issue relevant instructions for the AMP.
Concerning General Aviation
In accordance with M.A.302(h), for ELA1 aircraft not involved in a commercial operation, the owner, whether he has contracted a CAMO or not [see M.A.201(i)], has the option.
Not to submit the Aircraft Maintenance Programme (AMP) to the competent authority for approval, but instead
‘Declare’ an AMP, subject to compliance with the conditions described therein.
In this respect, the owner may decide to deviate from the applicable scheduled maintenance recommendations (see also remark below) without the need to justify such deviation(s), but under his/her full responsibility. Such declared AMP does not need to be sent to the competent authority.
In this scenario though, the declared AMP shall not be less restrictive than the ‘Minimum Inspection Programme’ (MIP) referred to in point M.A.302(i).
A clear overview of the different options for the development (including the source of information and potential customisation) and approval of such an AMP is provided by ‘GM M.A.201(i), M.A.302(h) and M.A.901(l)’.
Annual Review General Aviation
In addition, such declared AMP shall be reviewed annually and this review can be done either by the person who performs the airworthiness review, during the accomplishment of the airworthiness review or by a CAMO if contracted to manage the continuing airworthiness of the aircraft [see M.A.302(h)5].
In accordance with M.A.302 and in particular M.A.302(h)(3), the AMP, declared or approved, shall in all cases include all the mandatory maintenance/continuing airworthiness requirements, such as repetitive Airworthiness Directives or the Airworthiness Limitation Section (ALS).
In accordance with Part-M Appendix VIII point (b)(9), the tasks that are part of the annual or 100h check contained in the ‘Minimum Inspection Programme’ do not qualify for pilot-owner maintenance referred to in M.A.803.
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Tags:
Aircraft Maintenance Programme, Maintenance Planning Considerations
